The release date for clinical quality measure specifications under the proposed Stage 2 meaningful use criteria does not provide enough lead time for review, development and certification efforts by vendors, and implementation by providers, according to the Healthcare Information and Management Systems Society.

“This presents a significant risk to patient safety,” HIMSS contends in a comment letter to the Centers for Medicare and Medicaid Services. Seventy-nine of the proposed measures for Stage 2 don’t have final electronic specifications to support comment on whether they are feasible and can be efficiently implemented, the letter notes.

“Furthermore, the expected publication date will allow only slightly more than 12 months during which vendors must analyze the specifications, update software and certify their EHRs. Providers must implement that upgraded software, and then providers must train caregivers on the requisite data collection and any associated workflow changes, in order to be ready to begin data collection by October 1, 2013. This timeframe is unrealistic and may jeopardize patient safety by truncating normal testing and validation activities. The presence of numerous challenges with Stage 1 eMeasures proves the case for allowing as much time for testing specifications as possible.”

Consequently, HIMSS recommends Stage 2 include only clinical quality measures that have final specifications published, are evaluated under the Manufacturing Automation Protocol and National Quality Forum-endorsed no later than June 2012, giving 15 months for implementation.

HIMSS’s letters on the proposed rule and EHR certification program under Stage 2 are available here.

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